Case Law Details
Jhalawar Kendriya Sahakari Bank Ltd., Vs ADIT (I&CI) (ITAT Jaipur)
Introduction: The case of Jhalawar Kendriya Sahakari Bank Ltd. vs. ADIT (I&CI) revolves around a penalty imposed for non-compliance with tax filing regulations. This article provides a comprehensive analysis of the legal proceedings and the verdict of the ITAT Jaipur.
Detailed Analysis: The appellant, Jhalawar Kendriya Sahakari Bank Ltd., challenged the penalty order issued by the ld. CIT (Appeals), NFAC Delhi, dated 24.06.2022, concerning the assessment year 2019-20. The grounds of appeal primarily questioned the validity of the penalty order, amounting to Rs. 1,50,000, imposed under section 271FA of the IT Act, 1961.
The bank, registered under the Co-operative Society Act, cited genuine reasons for the delay in filing the Statement of Financial Transaction (SFT). Despite filing the SFT along with reasons for the delay, the revenue authorities upheld the penalty. However, the appellant argued that the delay stemmed from operational challenges, including network connectivity issues in rural branches and a lack of technical expertise among branch managers.
The appellant emphasized that the breach was technical and venial, lacking any contumacious conduct or deliberate defiance of the law. Judicial precedents were cited to support the contention that penalties should not be imposed in cases of technical breaches without evidence of deliberate wrongdoing.
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